1 Recent Enforcement Actions Involving the Sale of Variable Annuities Commission Actions In re Raymond A. Parkins, Jr. (SEC Release No (January 18, 2002)): The Commission found that Parkins, an investment adviser and agent registered in Florida, induced his advisory clients to switch their variable annuities by providing them with unfounded, false and misleading justifications for the switches, and by misrepresenting or failing to inform his clients of the sales charges associated with the switches. As a result of Parkins fraudulent conduct, his clients incurred unnecessary sales charges, and in some cases lost a portion of their investment principal, while Parkins received commissions of more than $210,000 for the transactions. The Commission censured Parkins, barred him from the industry with a right to reapply after two years, and ordered him to pay disgorgement in the amount of $214,656, plus prejudgment interest. Securities and Exchange Commission v. Gregory P. Waldon (No.S (E.D. Cal.)), In the Matter of Gregory P. Waldon, Exchange Act Release No (August 29, 2003): The Commission found that Waldon defrauded customers in connection with the sales of variable annuities, by soliciting them to switch out of investments they already had in variable annuities and use the funds to purchase new variable annuities, incurring costs and expenses in the process. The complaint alleged that Waldon acted with scienter, as he profited from the sales while the customers incurred increased costs or risks from the transactions, without offsetting benefits. The complaint further alleged that Waldon made material misrepresentations to customers, and omitted material information important to the customers, with respect to certain sales. The SEC found that Waldon recommended approximately 57 such switches between 1998 and 2001 in which his customers, most of whom were at least 70 years old and retired, received no economic benefit or lost money and incurred $200,000 in needless transaction costs while Waldon received approximately $275,000 in commissions. The Commission barred Waldon from the industry, with a right to reapply after three years. In the Matter of Donna N. Morehead, (Exchange Act Release No (June 26, 2002)): The Commission found that Waldon s supervisor, Donna Morehead, failed reasonably to supervise Waldon. The Commission found Morehead to have failed effectively to carry out her responsibility to review Waldon s transactions, including variable annuity switches, with a view toward detecting and preventing securities law violations. When confronted with red flags, Morehead relied upon the information provided by the registered representative, including verbal explanations that were demonstrably false. The Commission found that if Morehead had obtained other, objective information regarding the customers accounts, including the account statements, the registered representative s false justifications would have been exposed. In a settled Order, the Commission barred Morehead for one year from acting in a supervisory capacity with any broker-dealer, and ordered her to pay a civil money penalty of $10,000.
2 NASD Actions Prudential Securities, Inc. (Case Number C (February 15, 2001)): The firm was sanctioned for failing to prepare or maintain forms that were called for in its written supervisory procedures. For example, the firm required that an exchange form and worksheet be completed in connection with replacement activity, but in a number of instances the forms were missing. The firm agreed to a censure and fine of $10,000. Allmerica Investments, Inc. (Case Number C (February 15, 2001)): The firm was sanctioned for failing to design new account documents sufficient to enable principals to effectively review and approve the suitability of variable annuity transactions. More specifically, the firm s account documents provided two options for investment objectives: retirement or other. This information was not sufficient to enable principals to determine customer investment objectives. The firm agreed to a censure and fine of $15,000. Lutheran Brotherhood Securities Corp. (Case Number C (February 15, 2001)): The firm was sanctioned for failing to capture customer investment objectives in its account documentation. Further, the firm s written supervisory procedures did not require the gathering of customer objectives, but instead encouraged the brokers to obtain this information. The firm s procedures did not require a review of the allocation of premium payments to the underlying funds. The firm agreed to a censure and fine of $25,000. First Union Brokerage Services, Inc. (Case Number C (February 15, 2001)): The firm s written supervisory procedures were found deficient in that they did not adequately address the review of variable annuity transactions, did not require supervisory review of premium allocations to the underlying funds and did not address how certain delegated responsibilities were to be supervised. The firm also failed to obtain required disclosure forms, failed to evidence the delivery of prospectuses and failed to document customer suitability information in a number of instances. The firm agreed to a censure and fine of $32,500 (including $5,000 of disgorgement). American United Life Insurance Company (Case Number C (February 15, 2001)): The firm was sanctioned for using material in the promotion of variable annuities for tax-qualified plans that failed to disclose that the variable annuity provides no additional tax benefit. The material also failed to clearly identify the underlying funds within the variable annuity. The firm failed to develop written procedures for the review and approval of advertising and sales literature. The firm agreed to a censure and fine of $25,000.
3 Ralph C. Evans (Case Number C (February 15, 2001)): Evans was censured for making an unsuitable recommendation of a variable annuity contract to a public customer. The annuity was purchased in a trust account, partially on margin and partially with the proceeds from the liquidation of class B mutual fund shares. Evans did not perform an analysis to determine whether the customer s holding period would be long enough to outweigh the higher expenses of the product and the fees for liquidating the class B mutual fund shares. Evans consented to findings that the transaction was unsuitable and agreed to a censure and fine of $10,000 and restitution of $20,000. CUNA Brokerage Services, Inc. (Case Number C (December 5, 2001)): The firm was sanctioned for failing to establish and enforce adequate written supervisory procedures covering its variable product business. The procedures failed to adequately address review and approval of transactions, suitability of recommendations, training and supervision of representatives, and customer complaint handling. Additionally, the firm failed to maintain records that information was obtained in connection with customer suitability and exchange transactions. Three individuals, including two representatives and the compliance officer were also charged. One was charged with an unsuitable recommendation of a variable annuity to a customer. The second representative was charged with misrepresentation in that he failed to disclose that the annuity was subject to IRS penalties if the earnings were withdrawn before the customer was age 59 ½. The firm agreed to a censure and fine of $100,000, of which $25,000 was assessed jointly and severally against the compliance officer. The broker charged with the unsuitable recommendation was fined $5,000 and suspended for 10 days. The broker charged with misrepresentation was fined $2,500 and suspended for 5 days. Mutual Service Corp. (Case Number C (December 5, 2001)): The firm was sanctioned for failing to establish and maintain adequate written supervisory procedures covering its variable product business. Specific areas of deficiency included: principal review and approval of variable life insurance transactions, monitoring of surrenders and cancellations, use of exception reports, supervision by home office principals of variable product transactions by OSJ managers, and supervisory review of the allocation of premium payments to the underlying funds. The firm agreed to a censure and fine of $35,000. Tower Square Securities, Inc. (Case Number C (January 18, 2002)): The firm was sanctioned for failing to establish and maintain adequate written supervisory procedures related to monitoring branch office inspections, variable annuity and life insurance suitability reviews and registration of employees. In addition, complaints were filed against a former registered representative with Tower, Kevin B. Dermody, and his business partner, Randall J. Veselik. The three enforcement actions involve the
4 mishandling of the investment portfolio of the school system's deferred compensation retirement plan. Proceeds of an annuity liquidation, along with additional plan contributions, were used by Dermody to purchase securities and insurance products including investment contracts issued by a company organized by Dermody and Veselik. The majority of plan funds invested with Dermody and Veselik s company was lost through speculative trading. Tower Square Securities was fined $200,000 and directed it to make $4.3 million in restitution to the Jefferson Parish, (Louisiana) Public School System's employees deferred compensation plan. Conseco Securities, Inc. (Case Number C9B (August 12, 2002)): The firm was sanctioned for failing to establish and maintain adequate written supervisory systems and failing to maintain adequate documentation related to customer suitability information. The firm s procedures failed to address: review and approval of variable annuity transactions, collection and maintenance of suitability information, supervision of annuity sales, and surveillance of transactions for patterns of cancellations or surrenders. The compliance officer failed to enforce firm procedures when he was required to do so. The firm agreed to a censure and a fine of $65,000, of which $10,000 was assessed jointly and severally against the firm s compliance officer. American Express Financial Advisors (Case Number CAF (December 4, 2002)): The firm was sanctioned for omitting material facts when selling variable annuities into tax-qualified plans. In making some sales, registered representatives failed to disclose that variable annuities do not provide the benefit or advantage of tax-deferred earnings when purchased in qualified plans. In addition, in certain instances firm representatives did not adequately explain to customers the costs and features of variable annuities. Finally, the firm failed to establish, maintain and enforce adequate supervisory policies and procedures governing the sale of variable annuities and variable life insurance. The firm agreed to a censure and a $350,000 fine. InterSecurities, Inc. (Case Number C (May, 2003)): The firm was sanctioned for failing to establish and maintain adequate written supervisory procedures and systems for reviewing and addressing customer complaints and the sale of variable products. Specifically, the procedures did not adequately provide for identification of correspondence as complaints, and as a result certain complaints went unreported to NASD. The firm failed to obtain certain information related to customer suitability. The suitability of the firm s written supervisory procedures did not provide adequate guidance on the suitability of variable life insurance transactions. Also, the firm did not have a written policy requiring that principals review certain customer information for suitability. The firm agreed to a censure and a fine of $125,000.
5 Ralph T. Grubb (Case Number C (May 27, 2003)): Ralph Grubb, at the time employed by Banc of America Investment Services, Inc., was charged with an unsuitable sale of a deferred variable annuity to an 18-yearold high school senior who was seeking a safe investment for a $30,000 legacy while in college. When she graduated from college, she intended to use the funds for a down payment on a house or to buy a car. However, the annuity contract was subject to a ten percent additional tax on distributions prior to age 59 ½ and carried surrender charges that would have still been in effect when she intended to liquidate her investment. The complaint alleged that Grubb's recommended allocation of 100 percent of the customer's premium to one underlying fund within the annuity was unsuitable in relation to the customer's risk tolerance, and that the customer had no need for the death benefit feature of the annuity because she was unmarried and had no dependents. Moreover, the customer was in the lowest marginal tax bracket and had no need for tax-deferral, a principal reason for the purchase of variable annuities. The complaint further alleged that Grubb made an unsuitable sale of a deferred variable annuity to the customer's father for the investment of a legacy received by the customer's 16-year-old sister. Grubb settled the matter by agreeing to a 15 business day suspension and demonstration of an inability to pay a monetary sanction. Kevin S. Jones (Case Number C (May 27, 2003)): Kevin S. Jones was charged with an unsuitable switch of variable annuities. At the time, Jones was employed at Raymond James and Associates, Inc. The customer, a self-employed rancher, needed access to her funds and had an investment time horizon of two to seven years. During the sixth year of her ownership of a $300,000 variable annuity, Jones recommended that she switch to another variable annuity in the amount of $315,000, for which Jones received a commission of $8500. The original variable annuity would have allowed the customer penalty-free access to her money in eight months, but the switch resulted in limited access to her investment for the next nine years. The switch also caused the customer to pay a $1600 surrender fee. The switch resulted in no significant improvement in the death benefit for the customer and caused the customer to pay substantial increased annual costs. Over a sixyear period, these increased costs depleted the $15,000 bonus offered by the second variable annuity. Jones settled the matter by agreeing to a 10 business day suspension and a fine in the amount of $10,900, which included $8,500 in commissions. He also agreed to pay $1,600 in restitution to the customer. John Steven Blount (Case Number C ( January 12, 2004)): John Steven Blount of Lake Charles, Louisiana was barred from association with any NASD member and ordered to pay restitution in the total amount of $1,549, plus interest to 10 customers for unsuitable sales of variable annuities and mutual funds totaling over $6 million. The unsuitable sales generated almost $220,000 in commissions. NASD found that Blount s conduct involved a scheme to defraud investors and to frustrate attempts by
6 his employer to supervise his activities. The transactions took place between 1998 and 2001, while Blount was a registered representative of NYLife Securities, Inc. Blount s customers were older, conservative investors who were generally seeking current income from their investments. NASD found that Blount s investment recommendations exposed his customers to excessive market risk, lacked sufficient liquidity, and failed to address the customers needs for current income. In one instance, the customer was a 62 year-old retiree who wished to keep his principal investment safe, and had told Blount that he anticipated the need within a few months for $50,000 to buy a car and to make home repairs. Despite the customer s near-term need for liquidity, Blount recommended that the customer invest almost all of his liquid assets in a variable annuity contract that imposed surrender charges for early withdrawals during the first six years of the contract. Furthermore, Blount recommended allocating the investment to high-risk sub-accounts that were not consistent with the customer's desire to keep his principal safe. In order to buy a car and make home repairs, the customer was forced to draw on his home equity and subsequently had to take early withdrawals from his variable annuity to make the resulting loan payments. NASD also found that Blount misrepresented material features of the variable annuities in order to induce customers to purchase the products. Additionally, in an effort to circumvent his firm s review of annuity and mutual fund transactions, Blount directed his sales assistant to falsify firm records regarding customer s financial situations and investment objectives. Waddell & Reed, Inc., Robert Hechler, and Robert Williams (Case No. CAF (January 14, 2004)): NASD filed a complaint charging Waddell & Reed, Inc. for recommending 6,700 variable annuity exchanges to its customers without determining the suitability of the transactions. These exchanges, known as switching, generated $37 million in commissions and cost Waddell s customers nearly $10 million in surrender fees. NASD also alleged that according to its quantitative analysis, at least 1,400 of the firm s customers were likely to lose money by making these switches. Charges were also brought against the firm s former President, Robert Hechler, and its National Sales Manager, Robert Williams. In addition to other sanctions, NASD is seeking an order requiring the firm to disgorge commissions and compensate customers. According to the complaint, between January 2001 and August 2002, Waddell engaged in an aggressive campaign to switch the variable annuity contracts of its customers from those issued by one insurance company, United Investors Life Insurance Co. (UILIC), to very similar annuities provided by another insurance company, Nationwide Insurance Co. The Complaint alleges that in doing so, Waddell & Reed failed to take adequate steps to determine whether there were reasonable grounds for the customers to enter into these exchanges, such as determining whether the customers were likely to benefit or lose money from the exchanges, and failed to establish sufficient guidance for the sales force to use in determining the suitability of the exchanges.
7 Prudential Equity Group, Inc. (Case No. C (January 29, 2004)): Prudential Equity Group, Inc. (formerly known as Prudential Securities, Inc.) and Prudential Investment Management Services LLC, were fined $2 million and ordered to pay customers $9.5 million for sales of annuities, including variable annuities, that violated a New York State Insurance Department regulation and NASD rules. From November 1998 through mid-2002, certain Prudential employees repeatedly circumvented Regulation No. 60 of the New York State Insurance Department, which governs replacement sales of annuity contracts. The regulation requires documentation of two separate interactions with a customer, documentation of specific information about the old annuity contract, and disclosure of comparison information before a replacement sale can be completed. The regulation is intended to protect investors by requiring disclosure of information in order to reduce opportunities for misrepresentation and to allow investors to make comparisons between their current annuity and the proposed replacement annuity. In an organized effort to circumvent the regulation, Prudential employees compressed the procedures to one contact during which customers were instructed to sign, but leave undated, all required forms. Subsequently, employees would insert dates in the documents in order to create an appearance that the two-step procedure had been followed and that there had been an appropriate interval between the steps during which information had been obtained from the issuer of the annuity proposed for replacement. In some instances when customers had dated documents despite instructions not to do so, Prudential employees would alter documents so that it appeared that Regulation No. 60 and the two-step procedure had been followed. During the three and one-half year period at issue, Prudential completed 906 annuity replacement sales subject to Regulation No. 60, and a substantial number of these involved violations of the regulation. Additionally, during the same time period, certain Prudential employees prepared and used incorrect annuity performance illustrations in sales of annuity contracts. Prudential discovered the violations in mid-2002 when a review of a replacement sale uncovered altered documents. Prudential promptly reported the matter to NASD and other regulators, and in consultation with NASD, initiated a remediation program for all affected customers that will result in payments of more than $9.5 million. Michael H. Tew (Case Number C (April 7, 2004)): Michael H. Tew, of Dothan, AL, formerly employed by A.G. Edwards & Sons, Inc., was suspended for six months and fined $28,000 for the sale of three unsuitable
8 variable annuities. The first unsuitable sale was to an elderly couple, both of whom were 76 years old at the time of the purchase. Tew knew that the customers were about to enter an assisted-living facility and had a need for liquidity. He also knew that the customers indicated income as their primary investment objective and wished to preserve the principal of their investment for their heir. Investment in the variable annuity accomplished none of these goals. The variable annuity did not allow the customers full access to their funds for seven years without incurring a surrender charge. The variable annuity purchase did not produce income, because Tew recommended investment in capital appreciation and growth sub accounts. In addition, the investment failed to preserve principal for their heir because the death benefit applied only if the customers died before the tenth contract year. Finally, Tew sold the customers a Retirement Income Guarantee Rider that was only available to contract owners 75 years old or younger. At age 76, the customers were ineligible for this rider. Because the variable annuity accomplished none of the investment goals identified by the customers, the customers could not financially benefit from the purchase, rendering the recommendation unsuitable. Tew also made unsuitable variable annuity recommendations in two other instances. Tew agreed to a fine of $28,000 and six months suspension from the industry for unsuitable sales of deferred variable annuities. Debora A. Fruge (Case Number C (May 4, 2004)): Debora A. Fruge, of Sulpher, LA, formerly employed by Banc One Securities Corporation, was found to have made misrepresentations in connection with variable annuity sales, and to have forged certain documents. Fluge made misrepresentations to a customer regarding the balance of a variable annuity account, forged the customer's name to change of address forms, falsified a confirmation relating to the variable annuity account, and failed to provide truthful information to the NASD. Fruge's course of misconduct began with a misunderstanding between Fruge and the customer regarding the nature of the annuity. The customer believed the annuity to be fixed. However, it was, in fact, a variable annuity. Rather than address the misunderstanding, Fruge misrepresented the balance and attempted to conceal her misrepresentations by creating a false confirmation and redirecting the customer's statements and confirmations for delivery to the branch office. Although the firm had procedures to ensure that change of address forms were not changed to post office boxes or branch office addresses, Fruge avoided detection by changing the address through the variable annuity company, rather than through her firm. Fruge agreed to a bar from the industry. Daniel Karl Park (Case Number C (May 14, 2004)): Daniel Karl Park, of Frisco, TX, formerly employed by Northwestern Mutual Investment Services, was barred from association with any NASD member in any capacity for signing the name of his wife to six different variable annuity
9 withdrawal requests and then converting the funds without his wife's authorization. Park agreed to a bar from the industry. American Express Financial Advisors (Case Number C (May 20, 2004)): The firm was found to have failed to preserve certain records in a non-rewriteable, non-erasable format as required by SEC rules. The records included copies of account statements, certain confirmations, and letters sent to customers confirming changes of address. These violations came to light as a result of NASD's investigation of the activities of a former registered representative of American Express who made unauthorized sales and cash withdrawals totaling $124,900 from a customer's variable annuity and who then converted the funds. The representative avoided detection for almost two and one-half years because he had changed the customer's address on the records of American Express to the representative's own address. The firm was sanctioned for inadequate record keeping during a four-year period. The firm agreed to a censure and a $300,000 fine. Nationwide Investment Services Corporation and Nationwide Securities, Inc. (Case Number C (May 20, 2004)): These affiliated firms distributed variable products advertising that contained deficiencies, including failures to: prominently disclose the charges and fees associated with the product; explain that dollar cost averaging does not insure profit or protect against loss; clearly identify the product as a variable annuity and/or variable universal life insurance product, and provide a balanced presentation of the risks and benefits associated with investing in a variable annuity. Nationwide Investment Services Corporation also failed to implement procedures to obtain customer information critical to evaluating the suitability of a variable annuity investment. In many instances, the firm failed to obtain information about tax bracket, prior investment experience, annual income, liquid net worth, risk tolerance, time horizon, investment objective, customer age or the details of the product being replaced by the variable annuity investment. The firm also failed to provide registered representatives with specific guidelines for evaluating information obtained from a customer prior to recommending the purchase of a variable annuity. The firm was sanctioned for having inadequate procedures and systems governing their sale of variable annuities, and both firms were sanctioned for distributing advertising and sales literature that failed to make required disclosures regarding variable annuity investments. The firms agreed to a censure and fines totaling $175,000.
JOINT SEC/NASD REPORT ON EXAMINATION FINDINGS REGARDING BROKER-DEALER SALES OF VARIABLE INSURANCE PRODUCTS Office of Compliance Inspections and Examinations United States Securities and Exchange Commission
INFORMATIONAL Variable Contracts The NASD Reminds Members Of Their Responsibilities Regarding The Sale Of Variable Life Insurance SUGGESTED ROUTING The Suggested Routing function is meant to aid the reader
Page 1 of 5 FOR IMMEDIATE RELEASE: March 26, 2004 Agency Press Releases 2004 List 2003 List 2002 List 2001 List 2000 List 1999 List 1998 List 1997 List Search Press Releases CONTACT: David Blount, (601)
ROBERT L. MITCHELL (Admitted in California) MitchellR@sec.gov LLOYD A. FARNHAM (Admitted in California) FarnhamL@sec.gov HELANE L. MORRISON (Admitted in California) 44 Montgomery Street, Suite 2600 San
CHAPTER 2013-163 Committee Substitute for Committee Substitute for Senate Bill No. 166 An act relating to annuities; amending s. 627.4554, F.S.; providing that recommendations relating to annuities made
Cetera Financial Specialists LLC 200 N. Martingale Road Schaumburg, IL 60173-2096 BUYING A VARIABLE ANNUITY CONTRACT THROUGH CETERA FINANCIAL SPECIALISTS LLC General Considerations Before you buy any insurance
Robert W. Baird & Co. Incorporated Important Information about your Annuity Investment What is an Annuity Contract? An annuity is a contract between you and an insurance company, under which you make a
The Florida Senate BILL ANALYSIS AND FISCAL IMPACT STATEMENT (This document is based on the provisions contained in the legislation as of the latest date listed below.) BILL: CS/SB 166 Prepared By: The
Mr. Jonathan G. Katz Secretary Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-9303 Re: NASD Proposed Rule Relating to Sales Practice Standards and Supervisory Requirements
Case 2:13-cv-00753-DS Document 1 Filed 08/08/13 Page 1 of 13 Thomas M. Melton ( 4999) firstname.lastname@example.org Daniel J. Wadley (10358) email@example.com Attorneys for Plaintiff Securities & Exchange Commission 15
ADMINISTRATIVE PROCEEDING BEFORE THE MARYLAND SECURITIES COMMISSIONER IN THE MATTER OF: * ROBERT BRUCE SANDO, * File No. 2000-0140 Respondent. * * * * * * * * * * * * * * CONSENT ORDER WHEREAS, the Maryland
REVISED SUITABILITY IN ANNUITY TRANSACTIONS MODEL REGULATION Executive Summary Commissioners Thomas R. Sullivan (CT) and Adam Hamm (ND) chair and vice chair of the Life Insurance and Annuities (A) Committee,
UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 55946 / June 25, 2007 INVESTMENT ADVISERS ACT OF 1940 Release No. 2610 / June 25, 2007
UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES ACT OF 1933 Release No. 9066 / September 29, 2009 SECURITIES EXCHANGE ACT OF 1934 Release No. 60732 / September 29, 2009
SECURITIES ACT OF 1933 Release No. 8750 / November 8, 2006 UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 54720 / November 8, 2006 INVESTMENT
Guide to buying annuities Summary of the key points contained in this disclosure document Before you purchase your annuity contract, make sure that you read and understand this guide. While reading this
Index Growth Annuity 5 And 7 The Broker s Sales Guide To An Individual Fixed Annuity From The Standard With an Index Growth Annuity you ll find a rewarding combination of safety, tax deferral and choice.
Procedure Update Suitability of Annuity Transactions (NE L.B. 887) Effective Date: The rules stated in this Update apply to solicitations occurring on and after January 1, 2013. The company must establish
Guide to buying annuities Summary of the key points contained in this disclosure document Before you purchase your annuity contract, make sure that you read and understand this guide. While reading this
1 1 1 IN THE MATTER OF DETERMINING whether there has been a violation of the Securities Act of Washington by: Financial Services International Corp.; Candace Jean Lee; David Waldemar Asplund, Jr.; STATE
Regulatory Notice 10-05 Deferred Variable Annuities FINRA Reminds Firms of Their Responsibilities Under FINRA Rule 2330 for Recommended Purchases or Exchanges of Deferred Variable Annuities Executive Summary
Variable Annuity Suitability Form P.O. Box 64284, St. Paul, MN 55164 (800) 800-2638 woodburyfinancial.com This submission must contain the items listed below. If any of the following items in this submission
CALIFORNIA ANNUITY TRAINING 4 HOURS 1. A producer s obligation to ensure that an annuity is suitable ends. A. when the customer signs the application B. when the customer pays the first premium C. when
ADV Part 2A Appendix 1 211 E. High Street, Pottstown, PA 19464 610.323.5860 800.266.6532 www.mlfa.com Investment Advisory Disclosure Brochure March 25, 2013 This wrap fee program brochure provides information
Introduction Overview One Size Does Not Fit All Variable annuities are not a one-sizefits-all investment. Variable annuities are products that have gained great popularity because of retirement planning.
Case 3:15-cv-03620-D Document 1 Filed 11/10/15 Page 1 of 9 PageID 1 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION SECURITIES AND EXCHANGE COMMISSION, v. Plaintiff, Case
SECURITIES ACT OF 1933 Release No. 9752 / April 17, 2015 UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 74754 / April 17, 2015 INVESTMENT
AFAdvantage Variable Annuity from May 1, 2013 AFAdvantage Variable Annuity issued by American Fidelity Separate Account B and American Fidelity Assurance Company PROSPECTUS May 1, 2013 American Fidelity
The Individual Annuity a re s o u rc e i n yo u r r e t i r e m e n t an age of Decision Retirement today requires more planning than for previous generations. Americans are living longer many will live
Page 1 of 5 Variable Annuities: Beyond the Hard Sell May 27, 2003 The marketing efforts used by some variable annuity sellers deserve scrutiny - especially when seniors are the targeted investors. Sales
UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 78118 / June 21, 2016 ADMINISTRATIVE PROCEEDING File No. 3-16836 In the Matter of STEVEN
CHAPTER 26.1-34.2 ANNUITY TRANSACTION PRACTICES 26.1-34.2-01. Exemptions. Unless otherwise specifically included, this chapter does not apply to recommendations involving: 1. Direct response solicitations
CERTIFIED FINANCIAL PLANNER BOARD OF STANDARDS, INC. ANONYMOUS CASE HISTORIES NUMBER 27406 This is a summary of a decision issued following the June 2013 hearings of the Disciplinary and Ethics Commission
STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS SECURITIES DIVISION IN THE MATTER OF DETERMINING Whether there has been a violation of the Securities Act of Washington by: Robert Malecki; Homeowner
ANNUITY SUITABILITY WHY REGULATORS ARE CONCERNED Wisconsin Office of the Commissioner of Insurance Agenda Why regulators are concerned about suitability. When may a sale be unsuitable. Serious violations.
Memo from Compliance No. 2014-007 To: All CFSC Registered Persons From: Chester Hebert, CEO and President Date: November 17, 2014 Re: Retirement Plan Rollover and Updated Universal Switch Letter (D041)
NAIC Buyer s Guide for Deferred Annuities Prepared by the National Association of Insurance Commissioners The National Association of Insurance Commissioners is an association of state insurance regulatory
Variable annuities A tax-advantaged way to save for retirement Common terms Annuitant The person (may be the same as the contract owner) whose life expectancy is used to calculate the income payment amount
A CONSUMER S GUIDE TO Annuities Be secure and confident in the decisions you make Americans are living longer than ever before. How will they fund these extra years? There are many different approaches.
Presentation on Suitability in Variable Annuity Sales - How to avoid [Your Name Here] pays $2 million to Missouri, other states, over variable annuity sales Introduction: Jefferson City, Mo. - Two companies
Buyer s Guide for Deferred Annuities Fixed Table of Contents What Is an Annuity?...2 When Annuities Start to Make Income Payments... 2 How Deferred Annuities Are Alike... 2 How Deferred Annuities Are Different...
IN THE MATTER OF DETERMINING whether there has been a violation of the Securities Act of Washington by: Ronald Newman ; Jeffrey Scott Hollingsworth ; Milestone Life Settlement Fund, LLC; Milestone Investments
STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS SECURITIES DIVISION IN THE MATTER OF ) ) Waddell & Reed, Inc., and ) W & R Insurance Agency, Inc. ) ) ) Respondents. ) Order Number: S-0-0-0-CO01
Contact: Ken Woodard Director, Communications and Membership Services Phone: (416) 943-4602 Email: firstname.lastname@example.org MR-0069 April 14, 2008 (Revised February 22, 2013) MEMBER REGULATION NOTICE SUITABILITY
Item 1: Cover Page Selective Wealth Management LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Selective Wealth Management LLC.
Understanding Annuities Annuities ARE NOT INSURED BY FDIC OR ANY FEDERAL GOVERNMENT AGENCY MAY LOSE VALUE ARE NOT A DEPOSIT OF OR GUARANTEED BY ANY BANK OR ANY BANK AFFILIATE IFS-A092313 Ed. 01/2005 Letter
Buyer s Guide for Deferred Annuities Variable Prepared by the NAIC National Association of Insurance Commissioners This guide does not endorse any company or policy Reprinted by John Hancock Life Insurance
STATE OF NEBRASKA Department of Banking & Finance In the Matter of Envision Investment Advisors, LLC 1065 North 115th Street, Suite 150 Omaha, Nebraska; and Ryan M. Jindra 1065 North 115th Street, Suite
Form ADV Part 2A (Firm Brochure) HORAN Wealth Management 4990 East Galbraith Road Cincinnati, OH 45236 513.745.0707 www.horanassoc.com January 1, 2016 This document provides information about the qualifications
Retirement today requires more planning than for previous generations. Americans are living longer many will live 20 to 30 years or more in retirement. Finding a way to make savings last over such a long
Robert W. Baird & Co. Incorporated Important Information about your Annuity Annuities are long-term investments that may help you meet or supplement your retirement and other long-term goals. Annuities
IMPORTANT QUESTIONS YOU SHOULD ASK ABOUT JAMES KIRBY ACCOUNTANCY CORPORATION JAMES KIRBY ACCOUNTANCY CORPORATION Registered Investment advisor 2601 Saturn Street, Suite 106 Brea, CA 92821 6702 (714) 203
Effective: June 1, 2013 Requirement 8368 Sales Procedure Update - Suitability of Annuity Transactions (MN H.B. 791) In recommending to a consumer the purchase of an annuity or the exchange of an annuity
Guide to buying an offshore investment contract What you should know before you buy Offshore investment contracts are only available for sale to nonresident aliens of the United States and are not subject
ADMINISTRATIVE PROCEEDING BEFORE THE SECURITIES COMMISSIONER OF MARYLAND IN THE MATTER OF: * MATTHEW A. KRIMM * Case No. 2015-0120 and * KRIMM FINANCIAL SERVICES, LLC * and * ADAM DUSO * and * KAIROS CAPITAL
. Lincoln Financial Advisors Corporation Financial Planning Brochure March 26, 2015 Lincoln Financial Advisors Corporation 1300 South Clinton St., Suite 150 Fort Wayne, IN 46802 (800) 237-3813 www.lfa-sagemark.com
Woodbury Financial Services, Inc. Guide to Investing Woodbury Financial Services, Inc., Guide to Investing Table of Contents Who We Are..........................................................................
FORM ADV PART 2 Brochure Guardian Wealth Management, Inc. 311 SW Water Street Suite 210 Peoria, IL 61602 309/692 1460 Email: email@example.com Website: www.gwmanagers.com March 31, 2015 This brochure
INVESTMENT INDUSTRY REGULATORY ORGANIZATION OF CANADA IN THE MATTER OF: THE RULES OF THE INVESTMENT INDUSTRY REGULATORY ORGANIZATION OF CANADA (IIROC) AND THE BY-LAWS OF THE INVESTMENT DEALERS ASSOCIATION
Why is Life Insurance a Popular Funding Vehicle for Nonqualified Retirement Plans? By Peter N. Katz, JD, CLU ChFC This article is a sophisticated analysis about the funding of nonqualified retirement plans.
STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS SECURITIES DIVISION IN THE MATTER OF DETERMINING Whether there has been a violation of the Securities Act of Washington by: David Lyn Lenihan; AllianceCapital
Buyer s Guide for Deferred Annuities Table of Contents What Is an Annuity?... 1 When Annuities Start to Make Income Payments... 1 How Deferred Annuities Are Alike... 1 How Deferred Annuities Are Different...
IN THE MATTER OF DETERMINING Whether there has been a violation of the Securities Act of Washington by: Ronald Newman ; Jeffrey Scott Hollingsworth ; Milestone Life Settlement Fund, LLC; Milestone Investments
Broker-Dealer and Registered Investment Advisor Fee Disclosure of the Transamerica Financial Group Division of TFA This disclosure summarizes fees and other compensation received by Transamerica Financial
Reno J. Frazzitta Investment Advisor Representative 877-909-7233 www.thesmartmoneyguy.com Variable Annuities Page 1 of 8, see disclaimer on final page Variable Annuities What is a variable annuity? Investor
UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 69092 / March 8, 2013 INVESTMENT ADVISERS ACT OF 1940 Release No. 3564 / March 8, 2013
IRA Decision Guide JPMorgan INVEST You work hard for your money. Now keep it working for you with a JPMorgan Invest IRA. JPMorgan Invest One Beacon Street, Boston, MA 0208 (800) 776-606 jpmorganinvest.com
9 ANSWERS EVERY INVESTOR NEEDS TO KNOW ABOUT ANNUITIES You may have received, or have been asked to download, information about annuities produced by someone who doesn t sell them or doesn t believe you
An Insider s Guide to Annuities Whatever your picture of retirement, the best way to get there and enjoy it once you ve arrived is with a focused, thoughtful plan. Introduction 2 What is an Annuity?...
A CONSUMER GUIDE TO ANNUITIES INSURANCE ADMINISTRATION TABLE OF CONTENTS Who We Are...1 How We Help Consumers....1 Resources For Consumers...2 What Is An Annuity?....2 Five Basic Questions For Understanding
NATIONAL ASSOCIATION O F INSURANCE AND FINANCIAL ADVISORS August 6, 2004 Ms. Barbara Z. Sweeney NASD Office of the Corporate Secretary 1735 K Street, NW Washington, DC 20006-1500 Via Electronic Mail: firstname.lastname@example.org
SB 482 (Johnston, Chapter 974) Key Annuity Legislation California insurance consumers are protected against insurance company insolvency or impairment by the California Life and Health Insurance Guarantee
UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION INVESTMENT COMPANY ACT OF 1940 Release No. 30264 / November 15, 2012 ADMINISTRATIVE PROCEEDING File No. 3-15095 In the Matter of Respondent.
Variable Annuities Introduction Settlement Options Methods of Buying Annuities Tracking Separate Accounts Suitability Tax Deferred Annuities Using this study guide. This study guide is intended for use
Variable Annuities What You Should Know Information is an investor s best tool WHAT YOU SHOULD KNOW 1 2 VARIABLE ANNUITIES Variable Annuities Variable annuities have become a part of the retirement and
AMERICAN WEALTH MANAGEMENT, INC 1050 Crown Pointe Parkway Suite 1230 Atlanta, Georgia 30338 770-392-8740 or 1-800-633-4613 email@example.com This Brochure provides information about the qualifications
2. Full Name of Proposed Annuitant POLISH NATIONAL UNION of AMERICA referred to as the PNU - A Fraternal Benefit Society 1002 Pittston Avenue Scranton, PA 18505 1-800-724-6352 or 570-344-1513 1. Is Proposed
IMPORTANT TO READ This includes and incorporates by reference the Day-Trading Risk Disclosure Statement and the Truth-in-Lending Statement attached hereto (together, the Agreement ). Acknowledgments and
A GUIDE TO INVESTING IN ANNUITIES What Benefits Do Annuities Offer in Planning for Retirement? Oppenheimer Life Agency, Ltd. Oppenheimer Life Agency, Ltd., a wholly owned subsidiary of Oppenheimer & Co.
Retail Brokerage Account Application About this Application This is a. Please read it carefully, as you will select products and services, tell us how you want to communicate with us, and agree to certain
U.S. INVESTMENT POLICY GUIDANCE REPORT Making Your Money Last Everyone has individual retirement goals, but we all have one in common: ensuring our money lasts throughout retirement. Even a well-designed